From May 2015 onwards, after MHRD had released its official documents to structure and guide all the NEP consultations, and these NEP meetings within states and at the national level were in full swing, the content and process of policy formulation was critiqued by a number of organisations and individuals outside the government network.

The discussions/critiques provided below are restricted to this first period of NEP formulation, Jan 2015 – Oct.2015. It begins with my commentary followed by my extended critique of NEP processes as well as the content of MHRD consultation documents . The third sub-section is a listing of various articles/discussions dealing critically with these processes and document

My Commentary -NEP Formulation, Jan.2015 -October 2015.

The following is my commentary on the inherent limitations and and other deficiencies in the processes and the quality of the NEP consultations and documents which were so woefully incapable of providing the most basic of inputs required for a new national education policy.

Vast Majority of these MHRD-Planned Grassroots Consultations Were not Held : Those Held were Completely Behind Schedule

By August 2015, approximately 2.6 lakh consultations at the gram panchayat, block and local urban body level were to have been held. The official NEP website indicated that less than 1% of these consultations had been completed. While the meetings were actually scheduled to begin in June, in most states, the process had just started or was planned to be held, or had provided no information.

An update on the NEP website indicated that by September 2, 2015, when scheduled NEP consultations in all 669 districts were to have been also completed, the August figure rose to less than 8%. Only 7.5 % of all scheduled School Education meetings were held, while the corresponding figure for Higher Education was only 1.1%.

To maximize the number of consultations, MHRD went on overdrive since September’15, which included Ms Irani – the Union HRD minister – holding video conferences and personally traveling to the states. Though, between September and October the number of consultations dramatically increased, almost 75 % of the scheduled meetings were not held by October 30, 2015.

The following table attempts to review the progress of implementation of the ongoing NEP consultations by the end of October 2015

Type of NEP Consultations

Schedule of Implementation

Progress of Consultations Implementation

Gram Panchayat to State Consultations on School and Higher Education

By the end of September 2015, all 268,403 meetings on School and Higher Education were scheduled to be held, and recommendations posted

The official MHRD website indicates as of Oct. 30, 2015 only 25% of all meetings were held – 25.5% of School Ed, and 15.7 % of Higher Ed. Only 3 States reported completing all consultations by October 30, 2015. Unclear how many of the commendations of the meetings were actually then posted on MyGov portal as required, but the figure would have been lower than25% of all consultations.

Six Regional /Zonal Consultations of Groups of States

Oct. 2015-Nov.2015

Only 1 Consultation – North Zone – was held despite most of the participating states in the North Zone not completing their required gram panchayat to state level meetings

Thematic discussions

April-Sept.,2015 for 100 State and 12 National Level Consultations

Data on how many held not provided, but are behind schedule as these thematic discussions continued in October and are still ongoing

Thematic Online discussions

Launched in Jan.26, 2014 and ongoing

29,109 online suggestions posted on the MyGov.in portal as of November 3, 2015.

Limited Participation of Stakeholders and Limitations in the Quality of Consultations

The task of trying to get about 2.7 lakh local, state, zonal and national meetings completed by the end of October, 2015 and also get all their recommendations posted was always an MHRD exercise in fantasy.

As indicated in the table provided above, less than 25 % of all consultations had been completed, despite the strenuous efforts of the Union HRD Minister and the MHRD Department between September and October. At the field level, the consequences of MHRD cracking of the whip to maximize the number of zonal, state and intra-state meetings has been captured in the October 30 report in the press on the situation in Chandigarh.

Local meetings, whose recommendations were to have been considered at the North Zone conference, were only held the day before this larger consultation. Moreover, SMC members from NGOs were not invited for the local meetings. Most schools were not aware of the themes. Many who attended were not even aware of the purpose of the local meetings. This is partly because even the goal of the NEP is not stated in the NEP documents listing merely questions on various themes for discussion.

Anecdotal evidence indicates a similar pattern for the state and substate consultations held in other parts of the country. The focus of the organizers – state and local government education officials – was to meet new and impossible MHRD deadlines. Consequently, these meetings were orchestrated and dominated by government education officers and other officials, and mostly attended by government school principals and teachers, government invitees and some School Management Committee members.

Moreover, this meeting of new MHRD deadlines involved state and local education officials convening meetings hastily without adequate preparation and then scrambling to finalise the consultation recommendations and reports, as soon as possible, so that they could be uploaded without delay on the MyGov portal.

Since many states had not completed their meetings, another consequence of this delay and lack of preparation was that the 6 key zonal documents to produce the Draft NEP in the original MHRD strategy never materialised. But on the official NEP website, all of the 6 zonal conferences covering every state and union territory was completed in 6 three-hour video conferences between September and October, 2016!!

Deficiencies in Other Consultations

Thematic consultations were conducted by the ministry along with institutions like the University Grants Commission, All India Council for Technical Education, National Council for Teacher Education, National Council for Educational Research and Training and several centrally-funded universities and institutions.

The problem with many of these thematic consultations by apex national institutions were that their discussion agendas were straight jacketed, like the grassroots and state meetings, by the MHRD-list of themes and discussion points. Moreover, they were also for the most part essentially in-house deliberations with limited inputs from outside education networks, NGOs, academicians and experts. Finally, they were essentially recommendation-creating exercises on isolated issues, without taking a holistic and critical view of the many challenges confronting the educational system.

The least useful and trivial of the contributions were most of the approximately 29,000 online suggestions posted by the public. Not only constrained by the MHRD themes, the content of their suggestions were for the most part brief and limited, and were the views of those limited numbers of members of the public with access to the Internet

2. My Critique -NEP Formulation, Jan.2015 -October 2015.

I am reproducing the full text of my extended discussion on the content and process of NEP formulation during Jan. 2015 – October 2015. This was written in October 2015 just prior to MHRD constituting the Subramanian Committee to formulate the Draft NEP. Since MHRD had initially planned a different Draft NEP formulation process, some parts of my critique are not applicable.

But the original commentary is reproduced immediately below, as it reflects some of the main concerns about the content and process of NEP formulation during May 2015 – October 2015. These significant shortcomings are highlighted separately at the end of this Section because quite a few of them continue to be reflected in the content and formulation of the Subramanian Committee Report, and the MHRD document that immediately followed.

In addition to the text, the Table of Contents of my extended critique is provided below for a preview and direct link to the issues that are discussed.

Started in 2014, the New Education Policy (NEP) is a work in progress spearheaded by the Ministry of Human Resource Development, under the stewardship of Ms. SmritiIrani, the Union HRD Minister. The formulation of the 2015 NPE visualizes a bottoms-up approach beginning with about 2.4 lakh Gram Panchayat meetings, followed by discussions at each block, district, state, groups of states and national level meetings – more than 2.6 lakh meetings. These meetings will provide the recommendations and other inputs which will culminate in a draft NEP document by the end of this year.

The rationale for this critique is based entirely on the view that the current approach to formulating the 2015 NEP is deeply flawed and ineffective. What will emerge from the ongoing grassroots meetings, expert body consultations and online discussions to develop the final NEP document will merely culminate in an unmanageable plethora of views and opinions, ranging from the uninformed to the insightful, “signifying nothing” in the absence of a unifying narrative and context.

We are at a crossroads, and need to revisit where we are and consider which road we need to travel on. It is therefore important to remind ourselves of what is at stake. Our under 25 population at more than 600 million exceeds the total combined population of the United States, Russia, France and England. A fundamentally flawed approach to the formulation of the 2015 NEP will endanger the educational and developmental future of these and future generations of children and youth, and the overall development of our country.

Both the process of NEP formulation and the content of its documents are seriously flawed. The adopted bottoms-up approach will create an unmanageable tsunami of recommendations. It will be impossible to draft the required Consolidated Note on each theme based on these opinions and perspectives.

In the absence of any selection criteria, another complicating factor will be that it will not be possible to decide between informed and uninformed opinions, nor is it clear whether majority opinion should or should not prevail. Issues and questions have also been so worded so as to manufacture consent on contentious issues. Illustrative of this are the type of leading questions related to ICT in school education expected to elicit answers that endorse the preconceived MHRD position that, with some tweaking of current practices in schools, ICT can radically alter the quality of school education in India.

There are inherent flaws in the NEP documents. These include the lack any statement of vision analyzing the unresolved equity and quality concerns in the existing system of education, and articulating the new educational and developmental challenges. With little or no reference to, leave alone analysis of, past policies and schemes that continue to significantly affect the current educational system, and therefore with limited understanding of what has worked or failed, we cannot chart new initiatives to meet old and new educational and developmental challenges.

Finally, there are major deficiencies in the NEP documents. Significant important issues that have been neglected entirely, or merely tangentially referred to, include: RTE Act and its Implementation; Early Childhood Care and Education; Public – Private Partnership in School Education; Strengthening of State and Substate Academic Institutions; Financing of Education.

The last 3 months, post-September, 2015, of NEP formulation is crucial. Less than 10% of the consultations have taken place as planned. The state – level consultations are so behind schedule that not a single regional/zonal consultation will take place. The 6 scheduled zonal consultations were considered necessary to create the consolidated Status document, which then was to be converted by the National Education Task Force into the draft NEP.

Since a consolidated Status Note is necessary to keep the December deadline, we are likely to have one prepared behind closed doors by unknown authors. This will then most likely be presented as a “representative” document reflecting both grassroots and public opinion. This will be possible because none of the consultation recommendations are at present in the public domain. And neither in the existing MHRD schedule and time-line, is this Status document up for public discussion.

It is therefore critical that this new Status Note, which will be prepared soon, is widely circulated and discussed. So too should the draft NEP document. This was the missing step and major flaw in the conceptualization and scheduling of the formulation of the NEP. However, given the significant deficiencies in the existing NEP documents, and add to this the closed door approach to the formulation of the Status Note, the need for both this document and the draft NPE to be widely circulated and discussed becomes even more imperative. This is one way forward.

Why We Need to Take Immediate Stock of the Process of NEP Formulation and the Content of its Documents

1.A 2015 NEP Document by the End of 2015? Not Even Close

Since 2014, the MHRD Minister, Ms.Smriti Irani, has reiterated on many occasions that the NEP Policy document would be ready by December 2015. With this deadline in view, by April 2015, MHRD had prepared and circulated among the states a detailed plan – content and schedule of meetings- of various types of consultations leading up to the production of the 2015 NEP document.

MHRD had expected that about 2.6 lakh consultations at the gram panchayat, block and local urban body level would be completed by August, 2015. Data posted on the MHRD website indicated that less than 1% of these consultations were completed by this scheduled deadline. Most states had just started or were planning to start, and some had provided no information.

An update on the NEP website indicated that by September 2, 2015, when scheduled NEP consultations in all 669 districts were to have been also completed, the August figure rose to less than 8%. Only 7.5 % of all scheduled School Education meetings were held,while the corresponding figure for Higher Education was only 1.1 %.

The latest update indicates that by September 21, the School Education meetings rose to 10.1%, and the Higher Education figure was 1.6 %. Less than 10% of the scheduled NEP consultations were held.

Ms. Smriti Irani has constantly reiterated her view that the USP of the 2015 NEP was its bottoms-up approach, and that the voices of people who would be most affected by it needed to be heard first. In September, all the scheduled NEP consultations from gram panchayat to state were to be completed. By September 21, more than 90 % of them were still to be held, and only one state had met the MHRD deadline. Clearly, either this bottoms-up approach has to be conceptually revised or abandoned, or the deadline for the NEP Policy will have to be indefinitely extended.

2. In the Best Case Scenario in Which All the Scheduled Consultations Were Completed, What Would Be Likely to Emerge?

A single consolidated Consultation document will be placed before the National Education Task Force (NETF). This will include preparing consolidated notes on each of the 13 School Education themes and 20 Higher Education themes, by compiling and analysing the suggestion and recommendations arising out of the grassroots consultations from gram panchayats to states and regions, as well as thematic, online and national consultations. Finally, from this single consolidated Consultation document, the NETF is expected to produce the draft NEP document and submit it to the government.

Will the current approach provide the necessary inputs and recommendations to the NETF towards creating the draft NEP document? Take the best case scenario, where all the grassroots meetings up to the state level had been completed as scheduled by Sept.2015, and all the regional, national and thematic consultations completed shortly afterwards. What would be the enabling perspectives and recommendations that would be likely to emerge from this massive exercise in policy formulation?

2.1 Best Case Scenario – An Unmanageable Tsunami of Recommendations

If all the discussions were held on schedule, and the participants were to provide the expected recommendations on the questions listed in the 33 School and Higher Education themes, an unmanageable tsunami of recommendations would have emerged making the task of preparing a single consolidated Consultation document impossible.

Take for example, the number of recommendations that would have emerged if the 2.4 lakh NEP consultations of the gram panchayats were completed as scheduled by May 2015. These bodies were to discuss a set of predetermined questions on only 8 of the 13 School Education themes, and within these themes only certain questions asked for suggestions and recommendations. At a conservative estimate, each gram panchayat would provide a minimum of 25 separate recommendations – about 3 recommendations per theme.

Had all meetings been held, these recommendations that would have emerged from all 240,000 gram panchayat NEP consultations would have amounted to 6,000,000 recommendations. Similarly at the block level meetings meant to discuss only 10 of the 13 themes, it is estimated that each block would make at least 51 separate recommendations, amounting to a total of about 336, 600 recommendations for all 6,600 blocks. And, for the 669 districts who would be required to make on a conservative estimate about 92 recommendations per district for the 13 themes of School Education – 7 suggestions per theme – the total number would have exceeded 60,000.

In addition to these approximately 6.400,000 recommendations that would emerge from the gram panchayat, block and district level consultations, there would be many more emerging from the urban local bodies, state, regional, thematic and online consultations on the 13 School Education themes. By September 2, there were 23,400 online submissions. All of these are meant to be posted on the official MyGov portal. And this total does not include the recommendations on the 20 Higher Education themes ranging from block level to regional discussions, as well as thematic and online consultations.

The entire planning and scheduling exercise of these consultations was a utopian MHRD exercise trying to meet an impossible deadline set by the MHRD Education Minister. However, it would be missing the point to focus on blaming the education officials at the Centre or the State responsible for the less than 10% implementation success rate. Even if the deadline was indefinitely extended, and if 50% of the NEP consultations were held, those preparing the consolidated Consultation document for the National Education Task Force (NETF) would have still been overwhelmed and capsized by this tsunami of recommendations.

2.2 Will Majority Opinion Prevail? No Explicit Basis for the NETF to Choose Between Recommendations, Especially Conflicting Recommendations.

These recommendations that will be posted on the MyGov portal will be made by large numbers of people and organizations with hugely varying competencies. Many gram panchayat, urban local body and block level education officials, leave alone members of school management committees and the lay public, would find it difficult to analyse the strengths and weaknesses of their schools and recommend sound educational policy measures. This is also true of many high ranking government education officials at the State and Centre, as well as academics in our apex educational institutions.

On the other hand, there are many government officials and organizations, NGOs and others from Civil Society, who have considerable expertise and experience. Clearly, the overall quality of their recommendations would be better than the relatively less informed. However, the difficulty of selecting between them, especially if there are conflicting recommendations, is exemplified in the polarizing issue of English as the medium of instruction.

2.3 English as the Medium of Instruction : An Illustrative Case of Conflicting Recommendations

There has been in the last 15 years an exponential growth in the demand for English medium schools, while regional medium schools all over the country are in decline or show very limited growth. This demand is now being articulated by the urban and rural poor including tribals, and is reflected in the exponential expansion of low-cost private English medium schools.

Despite an official policy of encouraging schooling in the regional languages, and despite considerable national and international evidence of the wide-ranging benefits of mother tongue schooling, both urban and rural government bodies are now increasingly running English medium schools , or actively encouraging other private bodies to run them. Some Dalit leaders, and at least one prominent Indian industrialist, have made a strong and much publicised pitch for English as the medium of schooling.

So it may not be too surprising if in the grassroots consultations, there is a considerable demand for English schooling, including many from the lower middle class and ambitious poor, and their political representatives. And therefore, if in grassroots meetings, lakhs of people fervently support English as the medium of instruction in all primary and secondary schools, and a few thousand educators who have studied this issue should oppose this, would majority grassroots opinion prevail over an expert minority view in policy formulation?

Any optimistic view that surely expert opinion should and will prevail is contradicted by recent developments in the new state of Telengana. Making a critical policy decision based on what people want, the Chief Minister has recently proposed that all government schools should soon switch over to English as the medium of instruction. He is reported as saying that government schools were ruining children, and that his aim was to ensure that all poor children study in English medium schools right from the beginning, like their counterparts who could afford English medium private schools. Schemes are to be initiated to train English teachers in Telengana as it plans to transition to full-scale English medium schooling.

Finally, there may well be recommendations that will be in conflict because they are district, state or region specific. But since all recommendations will be posted on the MyGov portal, the problem will arise at the level of preparing the consolidated Consultation document as it attempts to adjudicate between recommendations –some conflicting – from all the grassroots, thematic, and online consultations.

How will those preparing the Consultation document for the NETF adjudicate between the thousands of recommendations coming from thematic, state and regional consultations? What will be the basis on which they will decide on conflicts between recommendations from states and regions, or the the mass demand for English medium school education and other contentious issues ? Should they take important educational policy decisions based on the opinions of people with limited background information and perspectives, which can have long term negative consequences for individual, cultural and national development? Can critical NEP decisions be based on a referendum on a variety of educational issues in which majority opinion prevails?

3. Orchestrating Responses Through Leading Questions

3.1 Orchestrating Responses on the No-Detention Policy

On a few important issues, the MHRD questions to guide the consultations are framed in such a way as to elicit a desired recommendation. Take for example, the RTE Act stipulation that no child should be detained at the elementary stage (Classes 1-8 ). There has been considerable media coverage of opposition to the no-detention policy with unverified claims that, since the RTE Act came into force in April1, 2010, learning outcomes have deteriorated because children are assured of not being detained and hence not studying.

The questions on the no detention policy have been framed by MHRD to guide the district and state level discussions in the following way: “Has the no detention policy improved learning outcomes of students? If not what are reasons and what changes can be suggested”. While the no detention policy can be supported on many grounds, even a knowledgeable supporter would find it hard pressed to find tangible evidence that it has actually improved learning outcomes. To therefore frame the question in this manner is not only restrictive, but it also suggests that if it does not improve learning outcomes, the no-detention policy needs to be changed. And given the current climate of opinion, many would think that it would be a good idea for schools to fail children.

Strangely enough in the thematic discussions to be initiated by apex government and other institutions, the sole MHRD question is “What is the general feedback of students, teachers and parents regarding the no detention policy?” In these thematic forums where participants were likely to have more informed debates, the participants were not asked for their considered recommendations but to report on their assessment of the opinion of stakeholders on the no-detention policy!!

3.2. Orchestrated Responses on ICT In School Education and Its Negative Policy Consequences

An entire theme is devoted to the use of ICT in school education, and here again the MHRD questions attempts to orchestrate desired responses .There is considerable evidence that without careful attention to the teaching-learning context, the impact of ICT on learning outcomes in schools is quite limited, if not negligible.

The most recent evidence for this is in the report published in September 2015, by the Organization for Economic Co-operation Development (OECD) entitled, “Students, Computers and Learning: Making the Connection”. It notes that education systems which have invested heavily in information and communications technology have seen no noticeable improvement in Pisa test results for reading, mathematics or science.

In India where reading and mathematics levels are considerably low, equally significant is the OECD report’s observation on ICT and equity: “Ensuring that every child attains a baseline level of proficiency in reading and mathematics will do more to create equal opportunities in a digital world than can be achieved by expanding or subsidising access to high-tech devices and service”

This understanding and nuanced view is not reflected in the content of the MHRD School themes which invites suggestions on how current ICT practices –pedagogically limited in most Indian schools – can improve teaching and learning and a host of other initiatives. And obviously with such leading questions, there is bound to be a ringing endorsement of the preconceived MHRD position, that with a little tweaking here and there , ICT as it is currently being implemented in our schools can radically improve the quality of school education in India.

Incorporating a more nuanced and realistic view of the potential of ICT would have not only positive consequences, but also different policy implications. Such a perspective would have as its critical focus how to integrate the use of ICT by students and teachers in their daily classroom experience to enhance the quality of teaching and learning, and evaluate whether ICT does in fact make a significant difference in learning and teaching. And if it does so, under what conditions and contexts.

A series of different questions and policy decisions would follow from such a focus including asking states to reviewing existing practices, identifying best classroom practices In India and abroad, initiate small and large-scale action-research projects for understanding under what conditions ICT improves teaching and learning; what kinds of learning and what new learning experiences can be facilitated by ICT, and spell out its implications for teacher training, etc.

4. Inherent Flaws in the Presentation of the Content of the NEP School and Higher Education Consultation Documents

4.1. Lack of Vision

The documents for the gram panchayat to state level discussions lists only questions to be asked for each of the 13 School and 20 Higher Education themes. For the thematic discussions, each theme has a short write-up, The School Education theme has an average length of about 250 words, and the Higher Education theme is around 460 words. The online discussions have much shorter introductions.

None of these write-ups have a reference to even the goal of the NEP, let alone a vision statement articulating the need for a new education policy within the context of unresolved issues of equity and quality, and new challenges facing the nation and its youth, and outlining developmental and educational goals within the framework of the the values and commitments of the Indian constitution.

The nearest explicit statement of a goal is on the Home page of the official NEP website –“The Government of India would like to bring out a National Education Policy to meet the changing dynamics of the population’s requirement with regards to quality education, innovation and research, aiming to make India a knowledge superpower by equipping its students with the necessary skills and knowledge and to eliminate the shortage of manpower in science, technology, academics and industry”.

An explicitly articulated vision in the School Education and Higher Education consultation documents would have given the subsequent discussions an overall sense of direction and purpose. What we have on the official website, unlikely to be read by most participants in the consultation meetings, is essentially a very important, but limited technocratic objective which can constitute only one of the NEP goals.

4.2. Ahistorical and Acontextual

In the School Education consultation documents, there is no attempt to evaluate the precious education policy –the 1986 National Policy- its achievements and failures. Missing too is an evaluation of the significant educational developments in the post-1986 National Policy decades. These include the growth of large-scale national schemes like DPEP and SSA to improve the quality of education and the growth of state academic support institutions like SCERTs, DIETs, Block and Cluster Resource Centres. .

Absent too in the NEP consultation documents is any evaluation of the implementation in the states of later developments like the 2005 National Curriculum Framework(NCF) and RashtriyaMadhayamikShiksaAbhiyaan (RMSA) In fact, the RTE Act which is the most important educational development in the decades following the 1986 National Policy is merely tangentially referred to, if at all.

The current NEP school documents are impoverished by this ahistorical and acontextual approach. Without an understanding of these important developments which have effected or continue to influence what is happening in our schools, without a sense of what has been attempted and succeeded or failed, we cannot chart a vibrant policy to meet new and old development and education challenges.

4.3. Absence of Statistics and the Lack of a Quantifying Framework

In both the School and Higher Education NEP consultation documents, there is a conspicuous absence of a quantifying framework which provides statistical information regarding relevant features of the educational system. There are no national, state or substate statistics on students on school enrolments, school dropouts, enrolment ratios, etc.. Neither is their information on the provision and qualification of teachers, nor about schools and their infrastructure.

Furthermore, while there is an entire theme devoted to Inclusive Education, none of the NEP consultation documents provide any relevant statistical information on the educational status of the socially and economically deprived groups like SCs, STs and Muslims, or children with disabilities. This lack of a quantifying framework and the absence of relevant statistics reinforces the lack of an understanding of where the educational system is, and a vision of where it should be heading.

Everybody will be affected negatively by the lack of a vision reflecting priorities within a quantified framework, particularly those from disadvantaged backgrounds. Unlike their middle and upper class peers, where home background advantages and availability of private schools and colleges compensate for the lack of special provision by the state, these children require active state-planned targeted and prioritised provisions for improving learning and access to quality education.

5. Major Deficiencies in the Content of the NEP Consultation Documents

Some of the important areas in the School Education themes that received no mention, or have received inadequate attention or merely tangentially mentioned in the NEP consultation write-up and questions, include the following:

Right to Education Act and its Implementation;

Early Childhood Care and Education (ECCE);

.Strengthening the Capacities of State and Substate Academic Institutions;

Financing of Education;

Public Private Partnership (PPP) in School Education;

Ensuring Learning Outcomes in Elementary Education

5.1. Right to Education Act and its Implementation

Since the 1986 Policy of Education, the most significant policy development in school education in India was the Right to Education Act which came into force on April1, 2010 giving, for the first time in India, all children the justiciable and revolutionary right to free and compulsory elementary education.

Providing free and compulsory elementary education of quality to all children in India as their fundamental and justiciable right has had as its consequence many implementation challenges. They include access to schools, enrolment and completion issues, quality concerns including norms and legal provisions related to school provision, teacher pupil ratios, instructional hours curriculum, assessment of students, no detention policy, etc… The most publicly known provision and also the most controversial is the RTE 25% Reservation Provision for certain groups of marginalised children in private schools.

Apart from the regular Education Department channels, the institutional mechanisms for monitoring and protection of child rights include the National Child Protection Rights Commission (NCPCR) and its state counterparts; the RTE Advisory Councils in every State, as well as various substate mechanisms like the RTE grievance redressal mechanisms.

More than 5 years after its enactment, various studies have indicated that implementation of the RTE Act is is extremely inadequate on access and retention issues, quality concerns, and even the mere constituting of legally mandated institutional mechanisms..

On the access, quality and institutional issues of the RTE Act, the NEP consultation documents have almost nothing or very little to to say. No mention is made of the RTE Act in the state and substate consultation documents. In the thematic documents, it is mentioned only a few times and that too in a limited manner. Except for the School Management Committees, none of the mandated RTE institutions or the 25 Reservation provision are even referred to in any of the documents.

The only 2 issues mentioned in the consultation documents relating to RTE quality concerns are the No-detention policy and the Continuous and Comprehensive Evaluation (CCE) on which recommendations are sought . And the Schedule to the Act which provides norms for school infrastructure, teacher pupil ratios, instructional and teaching materials, hours of instruction, etc., is mentioned only once in the thematic discussions. This solitary reference is to the RTE requirement that every school should have sports equipment!

Despite impressive gross enrolment rates of children in Classes 1-8 amounting to almost 200 million, the actual number of children who have never gone to school, attend sporadically or drop out also number in the millions. Most poor children are not receiving education of even a minimum quality. We still have large number of schools without basic infrastructure including toilets and drinking water, teaching-learning materials, and qualified teachers.

To provide the necessary inputs to the NEP draft policy document and to articulate significant change in elementary education, the NEP consultation documents should have focused on access to schools, enrolment and retention, quality and institutional mechanisms within an explicit quantitative RTE framework. Inexplicably, almost all these concerns are entirely missing in all the NEP consultation documents including national, state or substate relevant statistics on student enrolment, retention and dropouts as well as relevant information on schools to help understand the enormous challenges in implementing the RTE Act vision.

5.2 Early Childhood Care and Education (ECCE)

Almost half the children below five years of age are stunted in India — a staggering 60 million. They represent about one third of stunted children worldwide. Malnutrition of young children in India, according to the ex Prime Minister, Manmohan Singh, is a “national shame”.

In this connection, it should be highlighted that the first 1,000 days of life, between a woman’s pregnancy and her child’s second birthday, are recognised by child development professionals as the critical window of time for influencing lifelong health and intellectual development. The importance of good quality preprimary education(3-5 years) is recognized for its contribution to the holistic development of young children, and its positive impact on school learning outcomes. And it is increasingly being understood that the economic development of nations is linked to investments in wide ranging inputs to the under sixes.

Realising the importance of the entire span of early childhood, India now has a National Early Childhood Care and Education (ECCE) Policy (2013), that lays down the government’s commitment to providing the comprehensive inputs necessary for the holistic development of all children below six years of age.

Though one of the 13 themes in School Education is devoted to Child health, references to the age-group 0-6 years in the grassroots to state discussions is limited. All the questions refer to the School Mid-Day Meal scheme, and in this context overall references to the need for health checkups seem to refer to such measures undertaken in school.

Inexplicably, a fuller treatment of the early years is provided in the thematic discussions. Here equal attention is paid to those going to school as well as overall health and nutritional status of children below 6 years including the Integrated Child Development Scheme. But even here preprimary education concerns, as mentioned earlier, are only tangentially referred to in all documents.

According to the 2011 Census, India has a population of 158.7 million children in the population of 0-6 years – more than the entire population of Germany and France. Given the importance of the birth-5 years age group in itself, and as a foundational stage for the overall development and education of older school-going age students, the under sixes should have been treated as a separate issue in the NEP consultation documents.

Most participants in the NEP consultations would have been involved with schools and older children. A separate theme would have ensured that EECE experts and practitioners would have been specially invited for the meetings, leading to more informed and relevant recommendations. In this connection, it should be noted that the National 2013 ECCE Policy, which would have had important NEP policy implications, is not even mentioned in any of the consultation documents. Finally, treating ECCE as a distinct theme in the NEP consultations would have also given an important signal to a wider public that this stage was critical for all subsequent education and development.

5.3. Strengthening the Capacities of State and Substate Academic Institutions

With some variation in numbers and functions, almost every state has a State Council Of Educational Research and Training(SCERT), District Institutes of Training (DIETs), Block and Cluster Resource Centres. These State and Substate academic institutes have varied and important roles: curriculum, syllabi and textbook development; inservice training of teachers and education officials, development of training ,assessment tools and academic support materials; conducting assessments and research,etc.

Increasingly, during the last decade on all academic matters related to the improvement of the quality of education, the State and substate institutions have played the dominant role. But with few exceptions, these academic institutions are substandard, need new vision and leadership and significant institutional changes.

The only reference to these critically important institutions in the consultation documents is a question asking whether there were enough SCERT, DIETs and teacher training institutions in the district and state discussions. No sustainable and significant improvements in teaching and classroom practices, and learning outcomes is possible without policy measures to reform these institutions. It is inexplicable that their central role in educational change has not been recognised in the NEP consultation documents.

5.4. Financing of Education

In the 2015-16 Union Budget, there have been drastic cuts in the education budgets of a number of flagship government schemes that can potentially have serious consequences for the development and education of children in India. These include the National Nutrition Mission, ICDS, Mid-day Meal Scheme, RashtriyaMadhayamikShiksaAbhiyaan (RMSA) and SarvaShikshaAbhiyan.

The expectation from the Centre is that with increase allocations to the states and more autonomy on education expenditure, the state governments would more than compensate for these cuts. It is unclear whether this will happen, and whether these budgetary cuts may well signal a momentous and more permanent change in Centre-State funding relationships.

We will have to find more financial resources –government and private- to fund the increasing demand for access to good quality schooling. Given the competing demand on limited resources, and the need to expand access to quality schooling, the NEP consultation document needed to incorporate these and other relevant matters related to the funding of education, including important and contentious issues such as the quantum of school fees in private schools. However, in the NEP consultation documents, the only reference to it is in the state discussion document to the use of PPP models to fund universal secondary education.

5.5. Public Private Partnership (PPP) in School Education

Even if Central and State governments expand their overall education budgets significantly, there will still be a considerable need for private sector funding. While PPP in the form of grant-in-aid schooling began in the 19th century, since 1990 there has been an exponential expansion in private schooling of varying degrees of quality.

In more limited fashion, there have also been recently novel PPP attempts to improve the functioning of the government school system in various states including private management of public schools but which are publicly owned and funded; government paying NGOs for specific support services like teacher training and development of materials; provision of mid-day meals and ICT in schools.

The 12th Plan Report of the Working Group on Private Sector participation including PPP in School Education provides policy directions on how PPP in schools needs to be expanded and effectively implemented, without sacrificing overall national objectives. It also recommends PPP initiatives for revamping the Teacher Education System, including DIETs. Interestingly, this government document recommends a PPP model to set up cutting edge research centresspecialising in discrete educational areas such as reading, elementary mathematics, inclusive education and faculty development for teacher education.

In fact, one cannot think of a single important area of school education, including ECCD, in which PPP cannot make a significant contribution. For this we need to remove the constraints to private sector investment in school education, which the 12th Plan Report identifies as weaknesses in enabling policies, and deficiencies in frameworks for regulation, management and finance.

At both state and local levels there is considerable ad hocism in selecting private partners as well as areas for PPP initiatives, and consequently many instances of misuse as well as ineffective interventions. In this connection, the Plan document observes that “any PPP strategy, however, must fit into and be in line with India’s overall education sector priorities. Its effectiveness will be guided by the extent it helps to complement and strengthen public sector education service delivery”.

We need far more investment and participation from the private sector in education. There is at present considerable private sector interest for investing and participating in the school system, including improving the quality of government schools. Large corporates are also required to spend 2 % of their profits on CSR activities. The current consultation will clearly not help towards drafting PPP policy measures to meet this challenge, since the solitary reference to this issue in the discussion questions refers only to PPP models of funding secondary education. The NEP consultation documents have simply not understood the varying contributions that PPP can make, and that it can potentially be a game changer in school education.

5.6. Ensuring Learning Outcomes in Elementary Education

Unlike the above 5 important areas, an entire theme is devoted to learning outcomes in elementary education in the NEP consultation documents. The deficiencies in its content also illustrates many of the type of deficiencies in the other remaining 12 School Education themes.

First, the questions in the consultation documents deal with the learning outcomes in only some subjects at the elementary stage (Classes 1-8). These question focus on an important area- acquiring and teaching of early literacy and numeracy skills, and the training of teachers to teach these foundational skills. However, the elementary stage of education deals with many other important subjects. The 2014 NCERT document, “Learning Indicators and Learning Outcomes at the Primary Stage” has in addition to Languages and Mathematics, included Environmental Studies, Science, Social Sciences and Arts Education.

Moreover, except in the district and state-level discussions, even the focus on early literacy and numeracy skills covers only the primary stage (Classes 1-5). We know that in every class at the elementary stage there are large numbers of children, especially from socially disadvantaged groups, who do not acquire grade appropriate skills in language and mathematics. Moreover, little or no remedial education is provided which has repercussions for secondary and higher education.

We need to institute a large-scale scheme of remedial education from Classes 2-8 in our elementary schools in these subjects which goes beyond conventional tutoring assistance. This is a policy measure that needs to be widely institutionalised. But since remedial education is not mentioned explicitly in the thematic write-up and the list of consultation questions, it is not likely to feature as a critical NEP recommendation. In fact, in the entire write-ups and questions on the 13 School themes, the phrase remedial education appears only once in passing in the write-up on reforming the school examination system.

In fact, in terms of policy measures, there are other systemic issues that go beyond improving teaching in elementary schools and the training of teachers. First, we know that good quality preprimary education is important for all children, and especially poor children in terms of readiness for schooling and acquisition of early numeracy and literacy. Furthermore, we know that the reading levels of our elementary school textbooks are pitched too high, and consequently themselves contribute to the miserably low levels of reading comprehension skills of many Indian children.

Both the need for preprimary education and textbook reform theme is absent from the School Education consultations write-ups and questions, with 4 minor exceptions. First, in the thematic consultations on learning outcomes, there is an incomprehensible and somewhat bizarre question, “How do we factor in preprimary/ play school industry in our country that seems to be mushrooming”?!! In addition, the other discussions include a tangential reference to the role of the Integrated Child Development Scheme in providing preprimary education, while the importance of preschool education is referred to in the limited context of helping children to enroll at the age of 6 years.

And as for textbooks, which are still the primary source of information for all Indian students, it appears in only one question in the theme on secondary education in the entire consultation write-ups and questions: “Is there a need to improve secondary/senior secondary text books?”

The almost total disregard of preprimary education and textbooks can also be seen in the treatment of books and libraries, which are not mentioned at all in any of the consultation background materials. Good textbooks and supplementary reading materials would make a considerable difference to overall education in general, and to improving reading skills and learning outcomes in particular. The almost total lack of discussion of these fundamental educational resources should be seen in stark contrast to an entire theme devoted to ICT, and the extraordinary significance the NEP consultations attach to it despite its yet unproven role in improving learning outcomes.

Moreover, since the focus of current national discussions on learning outcomes is on improving the dismal levels of learning in government elementary schools, this is also the limiting focus of the content and questions in the NEP consultations devoted to it. It does not include, for example, other types of schools like our best metropolitan-based English medium schools which are particularly deficient when it comes to their students acquiring higher order and practical application of knowledge skills.

There is now also enough research evidence that in secondary schools and colleges, including engineering institutions, learning levels are in very bad shape. Learning outcomes and the teaching-learning process needed to be at centre stage in the School and Higher Education consultation documents. Given its cardinal role in individual, social and national development, it is a striking deficiency to limit the NEP consultation documents to learning outcomes in government elementary school, and not explicitly broaden the scope of discussions.

6. Post-September 2015 – Critical Emerging Concerns During the Final Stages of the Consultation Process

6.1. Consultation Meetings – Way Way Behind Schedule and Critically Important Scheduled Zonal Consultations Will Not be Held

The following table attempts to review the progress of implementation of the consultation meetings scheduled to be completed by the end of November ,2015.

Type of NEP Consultations

Schedule of Implementation

Progress of Implementation

Gram Panchayat to State Consultations on School and Higher Education

By September, all 268,403 meetings on School and Higher Education to have been held, and recommendations posted

The official MHRD website indicates as of Sept.21,’15, less than 10% of all meetings held – 10.1 % of School Ed, and 1.1% of Higher Ed. Only one State reported completing all consultations. Unclear how many recommendations were actually then posted on MyGov portal as required.

6 Regional /Zonal Consultations of Groups of States

Oct.-Nov., 2015

None going to be held on schedule as these can only be held after state level meetings and availability of state outcome documents.

Thematic discussions

April-Sept.,2015 for 100 State and 12 National Level

Data on how many held not provided, but are behind schedule as these thematic discussions are ongoing and some will be held in October,2015.

Thematic Online discussions

Launched in Jan.26, 2014 and ongoing

23,939 online suggestions posted on the MyGov.in portal as of September28, 2015.

Each of these 6 zonal consultations were scheduled to produce a zonal document which was to incorporate online suggestions; recommendations of all individual State level documents (on an average 5-6 states per region); major recommendations under each theme; recommendations on region specific issues on the thematic areas.

Six consolidated Status Notes on each thematic area was to be presented at national level meetings to be attended by stakeholder groups including GOIministeries. After these meetings, a single consolidated Consultation Document was to be placed before the NEPTF. After due deliberations, the NEPTF was to convert the Consultation Document to the 2015 Draft National Education Policy, which was to placed for consideration by the Central Advisory Board of Education (CABE) before the end of 2015

As the above table indicates, none of the consultations have been held on schedule. Less than 10% of the important grassroots consultations from gram panchayat to state were completed. Since only 1 state has completed all its grassroots consultations from the gram panchayat level upwards, no zonal consultations will be held as scheduled in October and November.

The Zonal consultations are vital to the formulation of the 2015 Draft NEP. It is the 6 Zonal Consultation documents which make up the Consultation Document, which gets converted into the 2015 NEP document by the NETF. How will the 2015 Draft NEP be prepared without a single scheduled zonal consultation?

6.2. Lack of Transparency: Consultation Recommendations Kept Out of the Public Domain

All recommendations from the village panchayat to state, regional and thematic discussions are meant to be posted on the MyGov portal. The official NEP website periodically updates the number of village panchayat to state discussions that have been held, as well as the online discussions. While the content of the individual contributions to the online discussions can be viewed by the public, the content of the far numerous and more important panchayat, state and thematic discussions which have been posted have been deliberately kept out of the public domain. As of the end of September 2015, this ban has not been lifted.

It is unclear why these posted discussions cannot be viewed, especially since the content of all online discussions can be viewed immediately as they are posted. And so while we know of the number of consultations that were held, we have no idea of the actual number and content of posted recommendations.

This lack of transparency is dangerous. The public will not know whose views are actually reflected in the draft NEP document to be prepared before the end of this year by the National Education Task Force (NETF). There is already a prevailing view that the ongoing NEP consultations have a hidden agenda, and consequently the ban on posting the recommendations in the public domain can only lend credence to this view.

As an ex-civil servant has noted: “Having been a part of MHRD for five years, I am also aware of the fact that all too often, “consultation” is used more for window dressing than for any actual input into policy making. The process ostensibly being followed by the government to craft its New Education Policy is suspect on many levels —–The inevitable conclusion then, is – as someone else has said – that the final document that gets produced will cherry pick the things government wants to do and include only those. Essentially, we can expect to see a document that outlines a limited vision of education that has roots in a particular political philosophy, which will be touted as the result of extensive consultation with all stakeholders”

6.3. Consolidated Status Document in the Absence of Zonal Consultations and the Lack of Public Scrutiny and Discussions?

As concluded in Section 6.1, the 6 Zonal Consultation documents were to be converted into a consolidated Status document, which the NETF was to convert into the 2015 Draft NEP. But since not one single Zonal document will be forthcoming in the next 2 months, will a consolidated Status Note be cobbled together?

In the absence of any guidelines from MHRD on this, and no revision of schedules of bringing out the draft NEP document by the end of the year, it is likely that some type of consolidated Status note will be cobbled together which may be presented as “representative”. There are various NEP consultations currently being held in different parts of the country by apex organizations like NCERT. All of these will be cited, together with other consultations held throughout the year to support the claim that this consolidated Status Note represents wide-ranging expert opinion of the country, as well as that emerging from the completed grassroots consultations

If such a document is presented, we need to scrutinise the process of its preparation. The public does not know how many of the thousands of completed consultations have actually posted their recommendations on the MyGov portal. Moreover, due to an MHRD diktat, it cannot access the content of posted recommendations from consultation meetings, except the online discussions.

As there is a complete lack of transparency of the process by which this consolidated Status note is being prepared, as well as who are its framers, it is then legitimate and necessary to speculate on why this needs to be done. What is it in the Status note that needs to be hidden from public scrutiny? Why cannot its content , as well as details on its framers- names, organisations they belong to and their designations – be made public. In this connection, it should be highlighted that the detailed MHRD blueprint of NEP formulation does not visualise and hence does not schedule, any public discussion of the consolidated Status document, nor the draft NEP that follows.

It is therefore critical that this new Status Note, which will be prepared soon, is widely circulated and discussed. So too should the draft NEP document. This was the missing step and major flaw in the conceptualization and scheduling of the formulation of the NEP. However, given the significant deficiencies in the existing NEP documents, and add to this the closed door approach to the formulation of the Status Note, the need for both this document and the draft NEP to be widely circulated and discussed becomes even more imperative. This is one way forward.

3. Links/References to NEP Grassroots, State and National Consultations/Process and MHRD Official NEP Documents and Guidelines, May 2015 to October 2015

School of Education Studies, Ambedkar University Delhi in collaboration with The Forum for Deliberations on Education, ‘Consultation on the National Education Policy 2015’, September 26, http://cprindia.org/sites/default/files/events/1_NPEConceptNote_Final.pdf